The Marine Environmental Impacts of Artificial Island Construction

Dubai, UAE

By

Bayyinah Salahuddin

Date: _______________

Approved:

_________________________ Dr. Michael Orbach, Advisor

Masters project submitted in partial fulfillment of the requirements for the Master of Environmental Management degree

in the Nicholas School of the Environment and Earth Sciences of

Duke University 2006

ACKNOWLEDGEMENTS

First, I thank Allah for making my research successful and rewarding.

Next, I would like to thank my dear family for their generous, unwavering support and

encouragement.

Finally, I would like to thank the Student International Discussion Group and the

Environmental Internship Fund at the Nicholas School of the Environment and Earth

Sciences at Duke University for funding my research.

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ABSTRACT

In the United Arab Emirates, Dubai is building three colossal artificial islands

each in the shape of a palm treein the Arabian Gulf. This has prompted several other

Gulf countries to construct artificial islands. To determine the impacts of the first of

these Palm Islands, The Palm Jumeirah, I traveled to Dubai and interviewed

governmental agencies, environmental groups, and the developers environmental

scientists. I analyzed the islands impacts on marine wildlife as well as the developers

mitigation efforts and the developers compliance with the relevant environmental laws.

The Palm Jumeirah has buried and asphyxiated wildlife, increased turbidity, and changed

the alongshore sediment transport. It has also created habitat along its rocky breakwater

and within its lagoons. The developer has implemented several environmental mitigation

measures, and has generally adhered to the Equator Principles. However, the developer

missed a few important opportunities to mitigate. Also, due to political pressure and legal

loopholes the developer has been allowed to ignore relevant environmental laws. In the

future, developers should adhere to local environmental laws, avoid building islands on

coral reefs, and adhere to the Equator Principles meticulously.

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TABLE OF CONTENTS

Introduction to the Country and the Region 5 Research Methods for Studying Dubais Palm Island 13 The Relevant Environmental Policies of Dubai and the UAE 24 The Palm Jumeirahs Beginnings 36 The Marine Environmental Impacts of Constructing The Palm Jumeirah 43

A Critical Analysis of The Palm Jumeirahs Impacts and Its EIA 57

Nakheels Remediation Efforts for The Palm Jumeirah 72

Conclusions and Recommendations 84

Works Cited 89

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INTRODUCTION TO THE COUNTRY AND THE REGION

Thirty years ago there was almost nothing here in Dubai. Forty-year-olds and Fifty-year-olds remember having to travel from Dubai to Abu Dhabi by camela journey that took eight days. Frederic Launay, Director of World Wildlife Fund-UAE

The United Arab Emirates (UAE) is a federation of seven city-states, or emirates

on the Arabian Peninsula. To its north lies the Persian Gulf, and to its east lies the Gulf of

Oman. The UAE shares its borders with Saudi Arabia, to the west and the south, Oman,

to the east and northeast, and Qatar to the northwest. The country was founded in 1971,

and the last emirate, Fujairah, joined in 1972. The UAE is a small nation that occupies

approximately 83,600 km2 (UAE Ministry 2004. 29). It is a federalist country, and each

emirate enjoys broad general autonomy (Nation Building) The UAE ranks as one of the

worlds largest exporters of petroleum (UAE Ministry 2004. 129), and revenues from oil

and gas constitute 30% of the gross domestic product (GDP) (United Arab Emirates).

Figure 1: The United Arab Emirates Reproduced from media.maps.com/magellan/Images/UAE-W1.gif

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The country is fully developed and boasts many features that surpass the western

world. In terms of political structure, the UAE has a president, but the nations highest

constitutional authority is the Federal Supreme Council. The Council, composed of the

seven emirate rulers, establishes general policies and sanctions federal legislation. Rulers

of Abu Dhabi and Dubai enjoy effective veto power. Abu Dhabi was selected as the

UAEs capital, but it was Dubai that became the young nations busiest port and its

principal commercial center.

Dubai city, the capital of Dubai emirate, lies upon the Arabian Gulf in the UAEs

northeast and contributes 66 km to the UAE coastline (UAE Ministry 2005. 280).

Dubais booming economy was built on revenues from the oil industry after oil was first

discovered there in the mid 1960s (Dubai Overview). However, Dubai has recently

sought to diversify its income and decrease its dependence on oil revenues. To this end,

Dubai has expanded its information technology, finance, commerce, and tourism

industries and invested heavily in modernization and development.

Dubais relentless striving has met with great success. Today Dubai enjoys a solid

reputation as the Arab worlds trading hub. By the year 2000, only 10% of its gross

domestic product came from oil revenues (ibid). Its efforts to increase tourism by

building hundreds of hotels, hosting the worlds richest horse race, breaking several

world records, offering special investment incentives, and welcoming all expatriates

have especially succeeded. The tourism sector is expanding faster than any other sector in

the citys economy (ibid), and it accounts for 22% of Dubais GDP (Samson and Davey).

In fact, Dubai now boasts the worlds highest revenue generated per available hotel room

(at US $175.47), beating out both New York and Paris (Dept. of Tourism). Famous

people from around the world including Michael Jackson, Donald Trump, Venus and

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Serena Williams, Andre Agassi, Boris Beckham, and Indian movie Star Sharukh Khan

visit Dubai to conduct business, shop, and enjoy its sunny weather and beautiful beaches.

By 2010, Dubai aims to attract 10 million tourists annually (Dubai Overview).

But Dubai has been running out of room for tourist attractions. By as early as the

1990s, hotels and ports had occupied Dubais entire coastline (Krane Arab Island

Resorts). To reach its staggering tourism goal, Dubai needed to find more beaches for

more tourists; it began to look for ways to artificially construct beaches.

The Ruler of Dubai, His Highness Sheikh Muhammed Bin Rashid Al Maktoum,

decided to build an artificial island in the Arabian Gulf off Dubais coast. He needed a

shape that would maximize beachfront space; he chose the shape of a palm tree.

Government-controlled Nakheel, the developer, was successful in constructing the first

Palm Island, and the beachfront real estate sold out to hotels and retailers before the

island was even constructed. Three-quarters of the buyers were foreigners (ibid). Soon,

the Crown Prince requested a second Palm IslandThe Palm Jebel Alithen a third

oneThe Palm Deiraeach one bigger and more elaborate than its predecessor.

Figure 2: The Palm Jumeirah

Reproduced with permission from Nakheel

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Figure 3: The Palm Jebel Ali

Reproduced with permission from Nakheel

Figure 4: The Palm Deira

Reproduced with permission from Nakheel

Nakheel also announced its plans to build The World, an exclusive 300-island

archipelago forming a map of the world. This incredible engineering feat is taking shape

4 km off Dubais coast. When completed, at a cost of $1.8 billion, The World will stretch

across a slice of the Arabian Gulf 9 km long and 6 km wide. An extensive breakwater and

several elongated, submerged reefs surround The World, protecting it from high waves

(The World Islands). The individual islands each span about 23,225 m2 to 83,612 m2

and are expected to sell for over $6.85 billion (ibid). The only mode of transportation

between these exclusive islands and the mainland is marine transit.

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Figure 5: The World Archipelago

Reproduced with permission from TEN Real Estate

Most recently, Nakheel announced the development of yet another land

reclamation projectDubai Waterfront. This colossal development will form a massive

circle adjacent to the second Palm Island, engulfing it in the Waterfronts massive

circumference. According to Nakheel, Dubai Waterfront will house 400,000 people and

will span an area 2.5 times bigger than Washington D.C. (Krane Dubai to Build).

Figure 6: The Dubai Waterfront Project Reproduced with permission from Nakheel

These elaborate projects and their success have prompted other emirates and

countries in the Gulf to develop tourism destinations of their own, in an effort to capture

a portion of the booming tourism industry.

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Figure 7: Schematic of all Nakheel's Projects. Note the Plethora of Artificial islands.

Reproduced with permission from Nakheel

The Emirate east of Dubai, Sharjah, has announced that it will build a $4.9-

billion, artificial-island archipelago, called Nujoom, or Star Islands, comprising 10

islands and covering 5.6 million m2 along the northeastern coast, 15 km from Sharjahs

center (Nujoom Islands).

Figure 8: Model of Sharjahs Nujoom Islands ProjectReproduced with permission from TEN Real Estate

Farther east, the emirate of Ras Al Khaimah plans to construct islands of its own.

It will spend $500-million to construct Saraya Islands, a project spanning one million

square meters in the Arabian Gulf (RAK Launches).

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In 2005 the neighboring Sultanate of Oman began its own dredge-and-fill project

set to approach completion in 2008 or 2009 (Samson and Davey). Omans $805-million

Wave project will occupy 7.3 km of beachfront (The Wave Oman) and 400,000 m2 of

reclaimed land (Oman Launches The Wave). It will feature 850 lavish apartments,

700 opulent villas, a marina housing 250 boat slips, and a plethora of luxurious hotels and

resorts.

Figure 9: Omans Wave

Reproduced from http://www.alaqariyaonline.com

The small island-nation of Bahrain is also heavily competing for a chunk of the

tourism industry. It is developing two artificial archipelagos: Amwaj Islands and Durrat

Al Bahrain. The Amwaj Islands, expected to reach completion in 2009 (Samson and

Davey), consist of almost 3 km2 of exclusive manufactured islands (Ossis Property

Developers). Durrat Al Bahrain is a $1.2-billion archipelago, set for completion in 2009

or 2010 (Durrat Al Bahrain: Ultimate Luxury). At a size of 20 km2, it will consist of 13

islands, and will require 27 million m3 of sand (MacDonald). Durrat Al Bahrain will

include enough villas, hotels, condominiums, and shopping centers to accommodate

30,000 residents along with 2,000 daily visitors (Durrat Al Bahrain).

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Figure 10: Durrat Al Bahrain

Reproduced from www.3dtotal.com/team/interviews

Not to be left behind, Qatar is building its own artificial archipelago 350 meters

off its shores. The Pearl Qatar will span 4 km2, house 30,000 people, and cost $2.5-billion

to construct (MacDonald). It will feature extensive marinas, luxurious hotels, upscale

retailers, and opulent residential properties. The project is nearing completion and is

expected to open to its first residents in early 2007 (United Development Company).

Figure 11: The Pearl Qatar

Reproduced with permission from TEN Real Estate

Any of these artificial island projects would serve as an enlightening case study

for understanding the marine environmental consequences of artificial island

construction, but studying Dubais first Palm Island seems most appropriate since that

island catalyzed all the other projects. And one is likely to find more data and information

on Dubais first Palm because it is the oldest. Any environmental lessons learned from

The Palms can perhaps be used to prevent repetitions of the same mistakes elsewhere in

the Arabian Gulf.

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RESEARCH METHODS FOR STUDYING DUBAIS PALM ISLAND

Officially, youll never get anything from Nakheel. Not their EIA and not their baseline studies. But you can try.

Anonymous Biologist, addressing me.

In 2005, I first heard about The Palm Island projects in Dubai. After surfing the

web for information, I learned of The Palms Jumeirah and Jebel Ali, their sizes, and their

designs. Initially, I was disinterested in studying The Palms and their environmental

impacts because I thought their primary impacts would be physical, hydrographical, and

meteorological rather than biological. I was wrong.

A marine biologist from the UAE later told me that The Palms were indeed

affecting marine biota, but no one, not even the government, was monitoring those

effects. Dubai Municipalitys Coastal Zone Monitoring Programme examines only the

topographical and hydrographical aspects of Dubais coastline, including the areas in

which The Palms are being built (Coastal Management Section). That was the extent of

the environmental monitoring related to The Palms. I once asked the former Secretary

General of the Environmental Research and Wildlife Development Agency, Dr. Saif Al-

Ghais, why government authorities were not studying the biological impacts of The

Palms. He responded in Arabic, Naymeen! Theyre asleep.

I decided to travel to the UAE in the summer of 2005 to study the marine

biological and environmental impacts of The Palms, but I knew that I couldnt discover

and document all the actual impacts in the space of a few summer months. Instead, I

planned to examine the perceived marine environmental impacts: what did the developer,

Nakheel, think were the marine biological impacts of its projects? And what was Nakheel

doing to mitigate the damage? Those were the questions I sought to answer.

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The problem was that only Nakheel could accurately answer such questions; thus,

I needed to see The Palms Environmental Impact Assessments (EIAs). Dr. Al-Ghais had

warned me that I would not be able to get them from Nakheel. Apparently Nakheel had

always said the EIA was public information, available to any member of the public who

asked to see it. Yet despite peoples requests for copies of the EIA, no one had actually

received one. Dr. Al-Ghais told me that I would never be able to convince Nakheel to

meet with me and discuss its projects. Consequently, for a long time, I didnt attempt to

contact Nakheel.

Instead, I chose the next best course of actioninterviewing environmental non

governmental organizations (NGOs), governmental agencies, and stakeholders to

ascertain The Palms perceived effects and Nakheels mitigation efforts. I traveled to

Dubai and began interviewing the appropriate people and organizations. Each time I

conducted an interview, I asked the interviewee to recommend others who might have

valuable information to share.

I also conducted online research, sifting through newspaper articles, trying to find

articles addressing the environmental impacts of The Palms. When I had searched the

web in the US, I had found only one article that mentioned anything negative about The

Palm projects. Even that article ended on a positive note. It seemed difficult to find

articles that didnt, at least, end with compliments for The Palms. One environmentalist

complained, Most articles about The Palms read like advertisements (Holmes).

Eventually, I did discover two articles that took a critical approach, pointing out the

potential for harm to marine fauna and their habitats.

In addition, I reviewed the environmental laws in Dubai and in the UAE to

determine if Nakheel was adhering to the relevant environmental regulations. I also

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examined the UAEs history to better understand the stage upon which Nakheels and

Dubais actions were set.

By the time I left Dubai, I had formally interviewed nine people, two of them

more than once. (There are 11 interviewees listed below.) I was careful not to tell the

interviewees until after the interview had commenced that I was focusing on The Palm

Islands. I didnt dare tell them so while trying to setup the interview via phone, because I

suspected that many of them would have refused to meet with me. When setting up the

interview, I only mentioned that I was researching coastal development in Dubai. Later,

at the interview, I explained my focus. Figure 12 lists all the interviewees and the

institutions they represent.

Figure 12: List of My Interviewees, Their Titles, Their Agencies, and the Interview Date

Interviewee

Title

Agency

Date of Interview

Country

Dr. Eisa M. Abdellatif Chief Technical Advisor Zayed International Prize for the

Environment 6/13/2005 UAE

Shaun Lenehan Senior Environmental Scientist Nakheel 6/15/2005

& 7/5/2005 UAE Anonymous Biologist Ministry of Agriculture and Fisheries 6/21/2005 UAE Ali Sagar Al Suweidi

Head

Emirates Environmental Marine Group 6/26/2005

Ibrahim N. Al-Zu'bi Environment Department Director Emirates Diving Association 6/26/2005

& 7/5/2005 UAE Khalid Mohammed Al Zahed

Head

Coastal Management Section, Roads and General Projects Sector, Dubai Municipality 7/2/2005

UAE

Mohammed Abdul Rahman Hassan

Head

Marine Environment & Sanctuaries Unit, Environment Protection & Safety Section

Environment Department, Dubai Municipality

7/2/2005

UAE

Dr. Shahid Mustafa Senior Marine Environmentalist Nakheel 7/5/2005 UAE Dr. Frederic Launay Director World Wildlife Fund (WWF)--UAE Office 7/13/2005 UAE Dr. Bernhard Riegl Associate Director National Coral Reef Institute 3/10/2006 USA Dr. Tom Williams Former Senior Technical Advisor Nakheel 3/18/2006 USA

Below, I outline the questions I created prior to the first interview. I used all or

some of these questions (depending on the interviewees agency and on whether or not I

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had already obtained an answer to a question in a previous interview) in my first four

interviews.

Figure 13: Interview Questions for My First Four Interviewees

Have any marine wildlife protection zones been setup in Dubai? What conservation laws have been enacted in the marine protection

areas? What marine protection laws have been issued for the Dubai

coastal/marine area? What enforcement measures have been put into place to protect these

areas? To protect all of Dubais marine wildlife? Where can I find the laws written out? Who makes the marine environment protection laws? Based on what do they make these laws? Has marine life been endangered, destroyed, or threatened due to this

activity? Approximately how much wildlife has been lost? What measures have been undertaken to ensure that marine wildlife and

the marine environment are protected? Are there any NGOs opposing the development of coastal Dubai? The

Palm Islands? Are there any environmental groups supporting The Palm Island

developments? Coastal development in general? Can marine wildlife protection occur without hampering economic

development and progress? How many scientists have been involved in assessing the impacts of The

Palms? Name some of those scientists. How long do you think it will take to attract new coral and establish a

new reef? What is the probability of successful coral recruitment? Are there any coastline laws to protect/limit human activities in the

marine environment? What is the role of tourism in protecting the environment? When was the last EIA of The Palms conducted? May I have a copy? Are the EIAs required by the law? Who conducts the EIA? What are some of the negative environmental impacts of island-

building?

The questions served only as drafts; and in the interview, I often worded the

questions differently and posed them in a semi-random order. I felt it was important to let

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the interviewee speak casually and naturally. If he answered a question before I had a

chance to ask it, I recorded his comments, and moved to the next related question.

I have found that the tenor of each interview is almost as important as the

interviewees comments; so, I will describe the interviews and the interviewees.

My first interviewee was Dr. Eisa Abdellatif, from the Zayed International Prize

for the Environment. I interviewed him because I had read in a newspaper that the Zayed

International Prize had partnered with Nakheel to install and monitor four units of two

artificial reef systemsin the waters of Dubai, just off the breakwaters of The Palm,

Jumeirah (Nakheel Testing Artificial Reefs). I began with the questions, then I let him

talk at his own pace, telling me about the reefs he and Nakheel tested. At the end, he gave

me copies of business cards to other stakeholders including some environmental

scientists at Nakheel.

For the next interview, I called Nakheel and spoke with Mr. Shaun Lenehan. He

immediately accepted my proposal to interview him about Nakheels Palm projects. He

showed me The Palm Jumeirahs EIAthe only EIA availableand he took me on a

tour of the island. In other words, he did everything I expected that Nakheels

environmental scientists would refuse to do. During our next meeting, he let me choose

sections from the EIA that were relevant to my study. (The EIA fills one-and-a-half 5-

inch binders and includes details about The Palms construction; no one outside Nakheel

was allowed to have a complete copy of such details. But Mr. Lenehan agreed to let me

have a copy of any purely environmental sections I selected, if my selection was small

enough to photocopy in a reasonable amount of time). Mr. Lenehan was forthcoming and

open about The Palms and Nakheels mitigation efforts. Lenehan answered all of my

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questions, and only directed me to Imad al-Haffar, Nakheels Research and Development

Manager, for three or four of my more-detailed questions.

My interview with Nakheels Dr. Shahid Mustafa was very different. Dr. Mustafa,

who had 10 years of experience working on environmental issues for Dubai Municipality,

seemed reluctant to share information with me. His response to half of my questions was

to refer me to either Shaun Lenehan or Imad Al-Haffar. However, Dr. Mustafa did give

me a copy of Nakheels Environmental Management Guidelines, outlining rules of

conduct at The Palm Jumeirah for contractors, landscapers, and residential and

commercial tenants.

The interview with the biologist at the Ministry of Agriculture and Fisheries went

well, but he could not provide much information because he was new to the area and The

Ministry (he is originally from another Arab country). He talked about the overall

environmental attitudes and challenges in Arabian countries. And he gave me a copy of

some of the relevant federal laws of the UAE and his opinions about The Palms.

My interview with Mr. Ali Sagar Al-Suweidi turned out to be a waste of time. For

the entire interview, which lasted an hour and a half, he refused to answer any questions

about The Palm projects. Instead he talked about Dubais heritage as a pearling village

and the pearls that still remain in Dubais waters. He took me on a tour of the Jebel Ali

Wildlife Sanctuary (JAWS). He was proud of that sanctuary, its terrestrial and marine

biodiversity, and its educational programs. But, he never mentioned that Nakheels Jebel

Ali Palm would eliminate the marine portion of the sanctuary, destroying the marine

wildlife he was so proud of. When asked about environmental awareness in the UAE, he

was very optimistic, often using Abu Dhabis remarkable environmental laws and

programs as examples. Abu Dhabi (the UAEs capital) has a strong environmental

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agency and many environmental measures; Dubai has no purely environmental

government agency and suffers from weak enforcement and implementation. However,

Dubai does have some good environmental programs, and Mr. Al Suweidi focused on

them. He was an optimist whose patriotic answers reflected well on Dubai and the UAE.

I believe that he avoided talking about The Palms because he wanted to prevent any

potential trouble. He never answered any of my subsequent phone calls.

Later that day I visited Ibrahim Al-Zubi. In contrast to Al Suweidi, Al Zubi was

a man who was not afraid to talk to me about The Palm Islands. Hed recently been

quoted, to his surprise and discomfort, in a widely circulated article. According to the

article, hed described the once-crystal-clear dive sites near The Palms saying, Visibility

is zero (Island-Building). Usually, and quite naturally, he expressed that he liked to

stop short of placing his neck directly on the chopping block, but somehow hed been

quoted in the newspaper. I think Al-Zubi is an optimistic realist; he accepts that The

Palms are here to stay, but he is concerned about the constructions biological impacts.

As an Arab, he felt proud of the projects; but as an environmentalist he was worried that

the Gulf countries were moving too fast, building massive islands before anyone had the

opportunity to learn from the first one. Al-Zubi taught me a lot about Dubai and his

interactions with Nakheel. In our second interview, I learned even more. For instance, I

learned that he respects the environmental scientists at Nakheel. He felt that they were

educated, qualified, and that they put forth remarkable mitigation efforts.

My next interviewee was Khalid Mohammed Al Zahed at Dubai Municipality.

What I gained from that interview was mainly in the form of magazines, articles, and

brochures. I took them off his coffee table; all-in-all I took about half of the items hed

stacked there. He was a newlywed, polite young man. He wanted to help me but couldnt

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give me the information I needed; he said he was not allowed to comment on The Palm

projects and the coastal processes they affected. (If only Id known that before setting up

the meeting! But that is what happens when you dont tell your interviewees that you are

seeking information concerning The Palms until after the interview has begun.) At the

end of our interview, Mr. Al Zahed asked Mohammed Abdul Rahman Hassan to meet

with me and answer my questions about JAWS.

Mohammed Abdul Rahman Hassan told me a great deal about Dubais wildlife

protection laws and JAWS. He even provided diagrams of JAWS and lists of its marine

flora and fauna. He pointed out that the marine portion of JAWS was on the brink of

destruction because Nakheel was building The Palm Jebel Ali there. He was extremely

helpful, explaining the laws and describing Dubais sanctuaries, but he knew little about

Nakheels projectsalmost no one at Dubai Municipality knew any details about The

Palms. Nakheel had excluded Dubai Municipality, and there was nothing the latter could

do about it. The questions I posed to Mr. Hassan and to Mr. Al Zahed are listed below.

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Figure 14: Interview Questions for Interviewees at Dubai Municipality

What enforcement measures (in terms of fines, fees, rangersetc.) have been put into place to protect Dubais marine wildlife?

What sort of marinelife does Dubai have? How much of the seafloor off the Dubai coast is barren and dessert-like? May I have a copy of the laws pertaining to coastal development and

EIAs (in English)? Through what processes are development projects approved if they fall

along the coast or in the water? May I have a copy of the EIAs for The Palms? Can marine wildlife protection occur without harming/ impeding

economic development? Can economic development occur without harming the marine

environment and its creatures? Which scientific companies have conducted the EIAs of The Palms? At what stage of planning and construction is an EIA required? At what

stage has it been carried out for Nakheels Palms? Which stakeholder groups were consulted in the planning stage of The

Palms? Exactly how has the island-building affected the alongshore transport of

sand and beach erosion? May I have the supporting data/figures/studies?

Are there any ecotourism projects planned or underway in Dubai? Where is the sand for The Palms dredged from? Has Island building affected water clarity and visibility? To what degree? The last person I interviewed in Dubai was Dr. Frederic Launay of WWF. The

questions I asked him are detailed below. He talked about more environmental issues

than those prompted directly by the questions, speaking casually and candidly about

everything from Dubais history, to its environmental laws, to Nakheel. His comments

were extremely insightful, helping me to put all that I had learned into context.

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Figure 15: Interview Questions for the World Wildlife Fund

What is your general view of the coastal development going on here in Dubai?

What is your general view of the marine environmental protection laws and their enforcement?

Have any wildlife been threatened due to all this coastal development (The Palm projects in particular)?

What measures have been taken to ensure marine organisms are barely harmed by all this development and by island-building specifically?

Are there any environmental groups opposing coastal development in Dubai? What is your relationship with Nakheel? Do they consult you in their

environmental decisions? How long do you think it will take for chemical and physical recuperation? How has the island construction affected Dubais natural beaches? At what stage is environmentalism here in the UAE? Are there any environmentally-friendly tourism operations planned for

Dubai?

The next stakeholder I interviewed was Dr. Bernhard Riegl, in the United States.

He is the Associate Director of the National Coral Reef Institute in Florida. Dr. Riegl had

been recommended to me by almost all of my interviewees in Dubai. He was well known

among them because hed studied the coral communities along certain sections of Dubai

for over a decade. His scientific papers provide detailed information about the coral

species that live along Dubais coast, especially in the Jebel Ali Wildlife Sanctuary. Dr.

Riegl shared his most relevant papers with me. He also shared invaluable information

about Dubais coral and the Gulfs benthic habitat.

My next interviewee provided even more invaluable information. Dr. Tom

Williams is the last person I interviewed for this study. Hed worked at Nakheel for five

years and had served as Nakheels Senior Technical Advisor until about one and a half

years ago. Since he was no longer employed by Nakheel at the time of the interview, he

could freely divulge everything he knew about the projects. He knew all the details about

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The Palms and how Dubais benthos had looked before the construction began; and he

shared that knowledge with me.

There were others whom I wanted to interview, but who declined to meet with me

either because they did not want to discuss the topic, or because they did not think they

could help. I could usually discern the two types of people. Those wishing to avoid the

topic would say, Why dont you just speak to the developers. When I explained that I

wanted unbiased information theyd say. Well I cannot speak to you about that. Or if I

said, A scientist at Nakheel sent me to you, theyd ask which scientist? After I had

answered that question, theyd say, You spoke to him, so you should have what you

need already. I think that some of them had been anticipating a call from me. Once,

when I called a potential interviewee and introduced myself, he said, O, yes, yes. Ive

heard of you.

Another gentleman requested that my project-advisor send him a letter about my

research and that I give him the name of all my previous interviewees before he would

concede to an interview. I was in the midst of requesting the letter from my advisor when

the gentleman recanted his request and refused to meet with me at all. His unusual

request had been meant to be so outrageous that Id be unable to comply. My

determination called his bluff, and he declined to meet with me.

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THE RELEVANT ENVIRONMENTAL POLICIES OF DUBAI AND THE UAE I dont know if I am a good leader, but I am a leader. And I have vision. I look to the future, 20, 30 years. I take decisions and I move fast. Full throttle. His Highness Sheikh Muhammed Al Maktoum

The United Arab Emirates is a young nation, and the environmental movement is

still in its childhood stages. The World Wildlife Funds Fred Launay says:

Environmental laws and regulations are new here. Only three Federal laws relevant to coastal developments have been established: Federal Law No.7 of the year 1993 (as amended by Federal Law No. 30 of 2001) on the founding and establishment of the nations Federal Environmental Agency; Federal Law No. 23 of 1999 on the exploitation, protection, and development of marine resources; and Federal Law No. 24 of 1999 on the protection and development of the environment. (Launay) Federal Law No.7 establishes The Federal Environmental Agency (FEA), which

works with the competent governmental authority in each emirate to enforce the federal

environmental laws. According to Article 4 of Federal Law No. 7, the FEA is charged

with cooperating with the appropriate competent authorities to conduct the following

activities inter alia (Only points relevant to this discussion are listed; thus the bullet

numbers do not begin at zero):

6. Establish the required principles and basis for incorporating environmental considerations into the process of planning and development in the State, by ensuring that environmental considerations become an integral part of policy making, and by ensuring that environmental matters become part of the planning, execution and follow-up of development projects initiated by government or the private sector, applying the measures of environmental impact assessment [sic]. 7. Monitor all public and private development activities that might have an adverse effect on the environment and has to firstly give approval to such developmental activities before licensing them. The Cabinet will determine the types of project which might have adverse environmental impacts [sic]. (Fed. Law No. 7 of 1993, Article 4)

This federal law is important because it not only establishes a national environmental

agency, but also asserts the need for Environmental Impacts Assessments, ensuring that

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both private and governmental developers consider their projects environmental impacts

and that they do so early, during the planning phase.

Federal Law No. 23 primarily concerns fishermen and establishes fishing laws;

however, it does address coral reef protection:

Article (37) It is prohibited to establish artificial coral reefs made of any material in any ground of the fishing waters unless after the approval of the fishing regulations committee and obtaining a license from the competent authority as well as from the ministry to achieve any one of the following two purposes:

a) Conduct Scientific research b) Development and enhancing certain species of the living aquatic

wealth (releasing larvae, setting up reservesetc.) (Fed. Law No. 23 of 1999)

As I will explain later, this law applies to The Palm Islands because the developers plan

to establish artificial reefs surrounding at least one of the islands.

With regard to Federal Law No. 24 of 1999, it contains several chapters on

different environmental topics. Chapter 1 is titled Development and the Environment. In

the first section of that chapter, the federal law addresses the environmental impacts of

developments:

Article 3 [Relevant sections only]

The [Federal Environmental] Agency, in consultation, with the competent authorities and concerned parties shall set the standards, specifications, principles and regulations for the assessment of environmental impact of projects [sic] and establishments applying for license and shall specifically undertake the following:

1. Identification of categories of projects, which due to their nature may cause harm to the environment.

2. Identification of areas and sites of special environmental importance or sensitivity such ascoral reefs, natural reservations, and public parks. (Fed. Law No. 24 of 1999)

Article 3 is bolstered by Article 4, which emphasizes the EIAs importance, No project

or establishment shall start the activity before obtaining the license aforementioned in the

- 25 -

previous article including environmental impacts assessment [sic]. Even after a

developer submits an EIA and obtains a license, the developer must

Undertake regular analysis of wastes and monitor the properties of discharge and pollutants generated from such projects including degradable materials and keeping monitoring records and sending reports with the results to the Agency and the Competent Authorities. (Fed Law No. 24 Article 7)

Section 2 of Federal Law No. 24, titled The Environment and Sustainable Development

further addresses environmental protection during development and construction, making

environmental impacts necessary components in any development plans,

All Concerned Parties specially parties responsible fordevelopment shall consider aspects of protection of the environment, control of pollution, and rational use of natural resources when developing plans and when establishing and executing of projects [sic]. (Fed Law No. 24 Section 2 Article 9)

The final provisions of this federal law, addresses pre-existing projects:

Article 97 The owners of projects and establishments existing on the date of operation of this law and determined by the Executive Order, shall provide the Agency within a period not exceeding one year from the operation of the Executive Order, with a complete statement of their activities. The statement shall include their suggestions concerning precautions and measures to be taken so that the operations of the projects or establishment meet the required environmental standards. Article 98 Projects and establishments existing on the date of operation of this Law, shall amend their status according to its provisions and the provisions of the Executive Order within a period not exceeding one year from the date of operation of the Executive Order. The Board of Directors [of the FEA] may extend this period for another year if need so requires or the extension has justification acceptable to the Board. (Fed Law No. 24 Chapter 9 Article 97-98)

This ought to mean that older developments can not be grandfathered in, and that they

must adhere to the aforementioned environmental standards.

Dubai Municipality has also issued laws and regulations regarding EIAs. In the

Municipalitys Technical Guideline Number 53, it defines an EIA as a systematic,

- 26 -

holistic, and multidisciplinary process that examines the environmental consequences of

development actions in advance (Dubai Municipality). Clearly, the municipality expects

EIAs to be completed and submitted before construction begins on a new development.

The municipality provides step by step explanations and detailed guiding principles for

conducting EIAs. I outline several of the relevant guidelines below. (Bullet numbers are

non-sequential because I have left out all irrelevant bullets):

2. The objectives of Dubais EIA process are to predict and determine significant environmental impacts; to identify and incorporate into the project, appropriate abatement and mitigation measures; and to identify and incorporate safety and health plans. 3.3 [The Environment Protection & Safety Section (at Dubai Municipality)] EPSS will review the [Environmental Impacts Summary] EIS and assess whether the environmental considerations have been adequately considered and suitable mitigation measures proposed. 3.5 If the development is permitted, an Environmental Protection and Safety Permit is issued to monitor the development during construction and while it is in operation. 3.7 When the project is implemented, the EPSS is required to monitor the project to ensure compliance with Environmental Protection & Safety permit and legislation. [sic] (Dubai Municipality Env. Dept Env. Protection and Safety Section Technical Guideline No.53) As for the EIS, it must adequately describe the project, providing, inter alia, An

estimate, by type and quantity, of expected residues and emissions (water, air, and soil

pollution, noise, vibration, light, heat, radiation, etc.) resulting from the execution and

operation of the proposed project (Dubai Municipality). It must also include A

description of the likely significant effects, direct and indirect, of the proposed project on

the environment. Additionally, the developer must outline its efforts to protect the

natural surroundings. Dubai Municipality requires that EISes include A description of

the measures envisaged to prevent, reduce, and where possible offset any significant

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adverse effects on the environment (ibid).

If a project will have significant environmental effects, the projects founder must also

compose an Environmental Impact Report (EIR) describing the physical aspect of the project.

The EIR should outline residues and emissions by type, quantity, composition, and strength

including discharges into the water, emissions into the air, noise, vibrations, light, radiation, heat,

and deposits to the land or soil. Dubai Municipality also expects developers to consider

alternative sites and methods. Hence, the EIR is to include Main alternatives sites and processes

considered, where appropriate, and reasons for final choice. (Dubai Municipality). Natural

reserves and protected areas must receive special consideration in the EIR: Where applicable,

the information under this section should include all relevant statutory designations such as

wildlife sanctuaries. The EIR must also outline the biological impacts in terms of Loss of, and

damage to, habitats and plant and animal speciesother ecological consequences physical

effects of the development, e.g. change in local topography, soil erosion, etc. The mitigation

measures to be included in the EIR are listed in Figure 16. Note that the report must include an

analysis of the proposed mitigations effectiveness. These EIA regulations, established by Dubai,

are further reinforced and supported by the FEAs own EIA guidelines. This reinforcement

establishes and highlights the importance of EIAs in the UAE.

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Figure 16: Environmental Impact Reports Must Include These Mitigation Measures

Dubai Municipality outlines the process by which its EPSS reviews the EIAs,

EISes, and EIRs as indicated in Figure 17. If properly implemented, this process would ensure

that all environmentally deleterious projects mitigate or compensate, for any environmental harm

caused.

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Figure 17: Dubais Review Process for Environmental Impact Assessments

The Palm Island projects are definitely massive enough and nature-altering

enough to require the execution of an EIA. In an Arabic document available on its

website, The Federal Environmental Agency lists the types of projects that would

necessitate EIAs. Based upon my translation of that document, the list specifically

includes the following:

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Projects for the discovery, extraction, manufacturing, storage, and transportation of sand or rocks, including whatever they contain of establishments and preparations of a related nature; all projects of marine transportation including docks, marinas, and piers without regard to their sizes; all projects for deepening marine channels and marinas and docks; and all marine bridge projects. (Qaa-imah AlMasharee)

If building The Palms did not involve all of the above activities, it would still necessitate

an EIA because all projects related to residential development also require EIAs.

Just as the EPSS at Dubai Municipality coordinates EIA implementation and

review, The Marine Works Unit supervises and manages the marine and coastal

engineering projects in Dubai. Anyone planning a project involving coastal dredging or

construction must first obtain a No Objection Certificate (NOC) from the Marine Works

Unit. The unit also anticipates and mitigates against potential environmental impacts of

coastal development projects (Coastal Management Section).

Lets now return to discussing Federal law No. (24). This federal law not only

establishes the legal importance of EIAs but also protects natural reserves and wildlife

sanctuaries. In Dubai, these areas are, in fact, protected under both federal and local laws

(which are issued by Dubai Municipality). According to Federal Law No. (24) Of the

year 1999:

Works, activities and acts prohibited in reserve areas which may lead to damage or deterioration of the natural environment, cause harm to wild or marine life or affect their aesthetic value, shall be determined by a decree issued by the Competent Authorities in coordination with the Agency. The following shall be particularly prohibited; [only the bullet points that were relevant to this discussion are listed; hence bullet numbers are not sequential] 1.Harming wild and marine creatures or undertaking activities leading to their

eradication. 2. Damaging or destroying geological or geographical formations in areas

considered natural habitat to animal and plant species as a result of increase or growth of such species.

4. Polluting the soil, water, or air of the reserve. 8. All that can disturb the natural balance of such reserves.

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It is also prohibited to set up establishments, buildings, or construct roads, drive vehicles, or practice anyindustrial or commercial activities in reserve areas without the permission of the Competent Authorities. (Fed Law No. 24 Chapter VI Article 64)

Even conducting environmentally damaging activities near a reserve is prohibited. It is

prohibited to practice any activities, acts or works in areas surrounding the reserves if

such practices affect the environment of the reserves or their natural phenomena, without

permissions from the Competent Authorities in consultation with the Agency (Fed Law

No. 24 Chapter VI Article 66).

Local laws further protect natural reserves which are often referred to as Protected

Areas. (See Figure 18.) The law protects the protected areas wildlife and habitats from

almost any imaginable, harmful activity. The only exception is provided, by a permit

from the competent authority [Dubai Municipality]. Without a permit from Dubai

Municipality, no one can conduct any potentially harmful activities without violating

both local orders and federal laws.

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Figure 18: Local Laws Protect Preserve Protected Areas

Thus far we have reviewed the three relevant federal environmental laws that Dr.

Launay pointed out and the complimentary local laws issued by Dubai Municipality.

Dubais local laws, orders, and enforcement measures have a large role to play, because,

according to Dr. Launay, the federal laws lack teeth. The laws provide general

frameworks but do not dictate methods of implementation, enforcement, or bylaws.

Bylaw establishment is left up to the competent authority in each emirate. Hence

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environmental bylaws, their implementation, and their enforcement differ from emirate to

emirate with the result that industries and firms establish themselves wherever the

environmental laws seem weakest. Even fishing regulations differ among the emirates

(Launay). According to a scientist at the Environmental Resource and Wildlife and

Development Agency, this disunity represents the biggest environmental challenge

currently facing the UAE (Anonymous scientist).

The Non-Emraatees I Interviewed thought the federal laws were too weak. But

the Emiratees thought their laws were strong enough. In their opinions, what their laws

lacked was enforcement. Dubai Municipality, for example, does not have the capacity to

adequately enforce local and federal environmental regulations, no matter the strength of

those laws.

Dubais political structure further complicates matters. Dr. Tom Williams, Former

Senior Technical Advisor to Nakheel explained the political structure to me as follows.

Dubais previous Ruler, Sheikh Maktoum Bin Rashid Al Maktoum, passed away

on January 4th, 2006. Before his death, his brother, Dubais current ruler, Sheikh

Mohammed Bin Rashid Al Maktoum, served as Dubais Crown Prince, and their other

brother, Sheikh Hamdan Bin Rashid Al Maktoum, served as Dubais Deputy Ruler.

Sheikh Mohammed and Sheikh Hamdan designed development projects to push Dubai

forward as a major hub for tourism, shopping, international commerce, and real estate.

Their projects were often jaw-dropping and outrageous, but they worked.

So environmentalists were often unwilling to call attention to the environmental

ramifications of such large development projects. If anyone complained about the

environmental issues associated with these large-scale development projects, he might

- 34 -

appear to be opposing developments that were critical to Dubais future, or even worse,

criticizing the Sheikhs.

Dr. Williams also says that Sheikh Mohammed was misled. Sheikh Mohammed

was under the impression that The Palm projects are environmentally sound and pose no

risk to sensitive marine wildlife like corals and mangroves. Why would he think that?

Because Sultan Bin Sulayem, Chairman of Nakheel, has assured him (and all of Dubai)

that "Methodical planning and exhaustive feasibility studiesensure that the islands can

be built without disrupting the environment. The area's natural resources remain

unharmed: not a single head of live coral has been touched in the process" (OFlynn).

Imad al-Haffar, Director of Research and Development at Nakheel, went even further,

claiming that The Palms would enhance the natural marine environment because Nakheel

plans to artificially attract and transplant coral to the areas surrounding The Palm

Jumeirah. Sheikh Mohammed has no reason to disbelieve them, especially since he

specifically instructed Nakheels Senior Technical Advisor, Dr. Tom Williams, (in the

presence of Sultan Bin SulayemCEO, and Saeed Ahmed SaeedManaging Director)

to protect the mangroves and coral reefs.

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THE PALM JUMEIRAHS BEGINNINGS

Development is happening too fast in Dubai; too fast for the social structure, too fast for the infrastructure; too fast for the people; too fast for the environment; and too fast for us to learn from our mistakes. Dr. Eisa Abdellatif

By the mid-1990s Dubai had discovered that it desperately needed more

beachfront so that it could build hotels, villas, condos, marinas, and a slew of other tourist

attractions that couldnt fit on Dubais 66 kilometers of already-crowded, natural

beaches. The present ruler of Dubai, His Highness Sheikh Mohammed Bin Rashid Al

Maktoum, who was at that time Dubais Crown Prince, conceived a bold plan to create

more beacheshe would build a massive artificial island in the waters of the Arabian

Gulf in front of Dubai. To boost Dubai as the tourism capital of the world, the island had

to be irresistibly attractive. It had to have a multifunctional shapeone that would

maximize beachfront space, reflect the emirates rich Arabian culture, and draw tourists

in like ants at a picnic. The crown prince mulled over several different shapescircles,

spiralset cetera.

In the end, he chose one of his own designs because it was unique and functional.

He chose the date palm tree. This design would represent the importance of dates and

date palm trees to the economy and culture of the region. And it would present dozens of

developable beaches, with the trunk and each frond providing beaches on both of their

sides. Furthermore, who could resist a palm-shaped island? It was perfect.

- 36 -

Figure 19: The Concept for Palm Jumeirah

Reproduced from www.thepalmdubai.com

To build the perfect island, the developer conducted three or four years of detailed

planning and feasibility studies (OFlynn). Wahid Attalla, an Executive Director at

Nakheel, said, From the very beginning of the project we have worked with the worlds

leading authorities to ensure that we are employing the most up-to-date technology and

are benefiting from the latest experience and data on the construction of man-made

islands (Dubai Review). He added, Only when the results of all of the studies had been

fully analyzed and our team was satisfied that work could begin did we enter the first

phase of infrastructure development. Next Nakheel hired the best firms in environmental

monitoring, marine engineering, and dredging and reclamation. Nakheel awarded most of

the reclamation work to Van Oord, a Dutch company. The Dutch have immense

experience in developing artificial land; they have done so extensively in their homeland

for decades. The people who built The Palm islands are world-class experts in marine

construction, engineering and reclamation. They come from a sea-affected nation such as

Holland, which has overcome the battle against the sea and they know exactly what they

are doing, said Wahid Attalla. All in all, several dozen contracted companies helped

conduct the research necessary to design and build The Palm Jumeirah.

Construction began on the island in June of 2001. The Palm was named Jumeirah,

in honor of the section of Dubai it would lie in front of. The eponymous Palm Jumeirah

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lies at about the center of Dubais coast. It is currently the worlds largest, manmade

island (although the third Palm will be the largest when it is complete). The Palm

Jumeirah spreads out in Dubais waters in an image so grandiose it is visible from space.

It spans over 5 km in width and 5 km in length and consists of 17 fronds atop a massive

trunk 450 meters wide and 2.4 km long (AAA freehold).

Construction firms worked around the clock configuring over 110 million m3 of

sand and 7 million tons of rocks (Van Oord). The rocks were brought over land and sea

from over 16 different quarries around the country. The sand was dredged from the

bottom of the Arabian Gulf in an area about 25 kilometers offshore of one of Dubais

ports. Placed end to end, the construction material could have formed a wall 2 m high and

0.5 m thick, circling the earth three times (Nakheel).

Nakheel also constructed a rocky, crescent-shaped breakwater surrounding the

island.

The outermost component is a crescentwhose outer faces are heavily protected with an engineered rock wall comprised of a layer of smaller rocks covering the outer sand slope, geotextile to provide initial coherence to the structure, and outer layers of rocks averaging about 1m3 in size that are individually placed and locked together. (Sale et al. 17)

The breakwater is 11 kilometers long and 200 meters across and can withstand waves up

to 5.2 meters high. Its triangular shape allows it to slow waves and force them to break at

a distance 15-20 meters away from the main structure. (Dubai: AlJuzzur Al-

Istinaaiyyah). At 5.2 meters above mean sea level, the breakwater extends 1.7 meters

above the height of the highest waves ever recoded in the area. Atop the breakwater is a

1.2-meter-high wall to further protect the development. Next to the wall lies a road that is

36 meters wide, providing a buffer against any unpredictably violent storms that might

- 38 -

occur hundreds of years hence. This breakwater is just one of the many things Nakheel

has implemented to protect the islands inhabitants.

Figure 20: Palm Jumeirahs Breakwater

Nakheel has also compacted the sand and rocks used to build The Palm. The sand

and rocks were compacted to such a degree that The Palm Jumeirah can withstand

earthquakes that register six on the Richters scale. Earthquakes are rare, yet the island

can withstand very strong ones.

And as global climate transforms, causing sea levels to rise, the breakwater will

be able to accommodate a one-meter rise in sea level. All these measures should prove

sufficient for protecting the developments sprouting up on the breakwater (on the other

side of the aforementioned road) and on The Palm itself as well as all its residents and

visitors.

Nakheel has invested heavily in protecting its future residents. But has it invested

heavily in protecting the marine environment into which it is placing all this rock and

sand, these buildings, boats, and people? To answer this question we must first look at the

Arabian Gulf and its condition pre-Palm Jumeirah.

- 39 -

The Arabian Gulf is an evaporative sea surrounded almost completely by dry,

dessert land masses. In the summers of this hot and arid region, the water temperatures of

the Arabian Gulf climb up to 50o Celsius. Such high temperatures lead to evaporative

losses of between 0.2g/m3 and 0.6g/m3 of water daily (Juhood Himaayat Albiy-ah 14-

15.) These high evaporation rates coupled with almost non-existent rainfall have

increased the Gulfs salt content over the millennia. Desalinization plants are also rapidly

increasing the Gulfs salt content. Hence, the Arabian Gulf is now known for its extreme

saltiness. On average, its saltiness ratio is 39-41.5 grams of salt to 1 kilogram of water. In

addition to high salinity, the Arabian Gulf is also characterized by shallow waters. Its

depth ranges from about 35 meters on the Arabian side to about 81 meters on the Persian

side. Also, the slopes leading into the basin are low and shallow; hence the waters of

Dubai are shallow enough to allow land reclamation.

The Gulf continually experiences strong winds, known as Shamals, that rush from

the North, gusting over the water, generating high waves and strong currents, and

scattering the yellow sands of Iran and Iraq over everything in their paths. (See Figure

21.) The Shamals are so strong that the subsequent currents (called Shamal currents) have

pushed sunken barges and planes around, on the bottom of the Gulf near Dubai (Al Zubi

interview, Abdellatif Interview).

- 40 -

Figure 21: The Shamals of The Arabian Gulf Reproduced with permission from NASA

All these characteristics make the Arabian Gulf both unique and fragile. The

creatures that live in the fragile marine environment must adapt to high temperatures,

high salinity, and strong winds and currents. They must also contend with anthropogenic

stresses from oil exploration, maritime transport, and coastal development.

Local and federal laws were recently instituted to protect these creatures and their

habitat from anthropogenic stress. For instance, any project with a magnitude similar to

that of The Palm Jumeirah would fall under every local and federal law that requires

EIAs prior to construction. In fact, according to Dubai Municipality laws, a developer

cannot even receive a permit to begin construction until it submits an approved EIA and

EIS. Yet when I visited Dubai Municipality in July of 2005, the Municipality explained

that the Environment Protection and Safety Section (EPSS) had not received an EIA from

Nakheel, nor had it received an EIS, nor an EIR. Nor had the Marine Works Unit issued a

No Objection Certificate (NOC) for the coastal dredging and construction. In short, every

applicable environmental assessment regulation seemed to have been tossed aside.

How could Nakheel get away with this? According to Frederic Launay, Director

of WWF, the applicable environmental laws, both local and federal, are all relatively

new, having only been passed after 1999. The conception and planning for The Palm

- 41 -

Jumeirah is older, so the laws dont apply to it. The Palm Jumeirah does not fall under the

jurisdiction of Federal Law No. 24 of 1999 which requires EIAs. Similarly, it does not

fall under any of Dubais local EIA orders. Nakheel was under no obligation to submit an

EIA for The Palm Jumeirah. Furthermore, Dubai Municipality lacks the authority and

jurisdiction to oversee The Palm Jumeirah project or ensure that the proper mitigation

measures are taken.

Surprisingly, Nakheel has developed an EIA for The Palm Jumeirah; it just never

gave the EIA to Dubai Municipality or any other government authority. Until now, no

one outside of Nakheel has ever reviewed The Palm Jumeirah EIA for compliance with

local standards. Nor has anyone evaluated the potential environmental damage from the

project or Nakheels mitigation plans.

(Nakheel says the EIA is technically available to the public, upon request. Yet,

the Emirates Diving Association requested the EIA, and never received it.)

Even so, Nakheels Mr. Lenehan acquiesced to my requests for copies of the

portions of the EIA that I felt were relevant to this research. In the upcoming sections, I

will analyze The Palm Jumeirahs environmental impacts. To do so, I rely heavily upon

data from Jumeirahs EIA and information from the interview with Dr. Tom Williams,

who holds degrees in geology, paleontology, and zoology and was formerly employed

with Nakheel as its Senior Technical Advisor. Dr. Williamss accounts are both valid and

vital because in his former capacity at Nakheel, he oversaw every aspect of The Palm

projects. Thus he was able to provide otherwise-unobtainable information.

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THE MARINE ENVIRONMENTAL IMPACTS OF CONSTRUCTING THE PALM JUMEIRAH

Coastal erosion in Dubai is causing worries, however, with more than 50 per cent of the 66-kilometer-long mainland coastline of the emirate eroding.Large-scale engineering projects offshore, of island construction in particular, are believed to be having a particularly adverse impact. UAE Ministry of Information and Culture

Appendix D in Palm Jumeirahs EIA consists of a Bathymetric, Geophysical,

Marine Ecological, Topographic, And Geotechnical Investigation conducted by a

consulting firm called Martin Mid-East. Martin Mid-East (MME) is a 13-year-old

company that specializes in bathymetric, ecological, and geophysical surveys and

assessments. The MME team conducted this particular assessment in the year 2000, one

year before construction began on Jumeirah. In the assessments executive summary,

MME says the following about the area where Nakheel planned to build The Palm

Jumeirah: (I have included only those bullets relevant to this discussion.)

The bottom types in the planned construction area consist primarily of consolidated and unconsolidated sands.

The areas of highest biological (macrofaunal and macrofloral) productivity are oysterbeds.

Three distinct oyster beds occur in the investigated area. One of which will be lost during the construction process.

Fish fauna and biomass is relatively poor. No significant fishery exists in the area. No critical habitats, like coral reefs or dense seagrass meadows, exist in the

investigated area. No endangered species that could not relocate exist in the investigated

areas. By creating artificial hard grounds, the construction of the Date Palm Island

could in some areas enhance biological diversity. It is suggested to develop the breakwater as an artificial reef (transplant corals

into the area) Most of the study area is characterized by caprock (lithified sand) overlain by

a variable amount of unconsolidated sand.

Let us examine how MME came to these conclusions.

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First, MME evaluated The Palm Jumeirah project based upon Nakheels plans for

its construction. By reviewing the construction plans, MME determined that The Palm

Jumeirah would affect the alongshore sediment transport and other physical

environmental processes.

This is a major project that will interfere with natural processes on several levels. Water transport, in particular longshore currents, will be diverted with possible resultant scour and accretion.[And] significant changes to local oceanography can be expected(2).

Martin Mid-Easts staff also determined that siltation would occur, increasing turbidity,

in the areas adjacent to the construction zone. In addition, the breakwater had the

potential to increase habitat complexity because it could provide a hard, rocky

substratum for marine life. Careful planning can generate an area of high natural and

recreational value. (2) Martin Mid-Easts approach seems pragmatic rather than

conservationist. It is concerned with both environmental and economical value.

While the beaches of Palm Jumeirah will attract tourists and provide economic

value, they come at the expense of some of Dubais natural beaches. The Palm disrupts

the alongshore sediment transport, starving the beaches:

Some sediment starvation can be expected downstream The longshore current will be forced to flow around the structure, which could lead to some increased current velocity and thus increased scour in some areas. Mathematical modeling would be necessary to confirm this. (27)

Indeed the beaches near Jumeirah have suffered greatly from a loss of sand, especially

the beaches to the east of The Palm, since the primary direction of sediment transport is

eastward.

Van Oord, the primary dredging contractor for Nakheel, indicated on its website

that it replenished seven beaches along eight km of coastline just east of The Palm

Jumeirah. The replenishment required over 3,500,000 m3 of sand and extended the

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beaches by approximately 30 meters. Van Oord then used 540 tons of rock to construct

three offshore breakwaters and extend one existing breakwater so that the beaches would

not erode so quickly in the future. Even so, Van Oord says the beaches will require

periodic maintenance in the future. Van Oord used to display a map of Dubai, with a

circle around the affected area on one of its webpages. (See Figure 22.) But Van Oord

recently changed that webpage and exchanged the map. The site no longer implicates The

Palm Jumeirah for preventing alongshore sediment transport; it now mainly blames

nature, alluding to The Palms effects in a manner that makes them appear secondary to

natures ravages Dubais beaches have always been prone to erosion from wind and the

rough waters of the Arabian Gulf. The large offshore developments in Dubai also

influence sediment transport along the beaches (Van Oord).

Figure 22: Old Van Oord Map Showing Eroded, Natural Beaches East Of The Jumeirah Palm

Reproduced from www.vanoord.com

Indeed, Dubais beaches lose large quantities of sand naturally. According to

Khalid Al Zahed, Head of the Coastal Management Section of Dubai Municipality, the

beaches used to lose 10,000-15,000 m3 of sand annually. (Dubai now uses dozens of hard

structures to armor its beaches). Dubais beaches are so small that they could not afford

to lose any more sand, said Al Zahed. Those beaches also couldnt afford to lose the

sediments that normally come to them via alongshore transport. I think that is why

Nakheel had to replenish the beaches its Palm affected.

- 45 -

Dr. Tom Williams confirms that The Palm Islands severely disrupt the alongshore

sediment transport, starving Dubais natural beaches of much-needed sand. He estimates

that the three Palm Islands combined alongshore sediment transport disruption has

starved over 40 kilometersthats over 60%of Dubais 65 km of natural shoreline.

The natural beaches are not the only ones that require continual renourishment.

Tides and waves have been reworking The Palms fronds. Nakheel will have to nourish

these beaches periodically as it tries to achieve an ideal, balanced state somewhere

between a natural, steady-sate equilibrium (in which waves completely rework the

fronds) and a controlled state (in which engineers keep the fronds perfectly in place). To

be sustainable, the renourishment periodicity must balance anthropogenic control and

natural erosion.

Let us now look at The Palms impacts on the underwater environment. In the

MME teams analysis of the topography, and geomorphology of the area, they state that it

is a shallow sloping seabed without any major features. The area contains low rocky

ridges, some of which represent broken-down, former coral areas. But MME asserts that

those ridges never formed more than one meter of positive relief (3). The rest of the

seabed MME characterizes as mainly sand or mud, with small wave and current ripples

visible in the sand. These tide-generated ripples usually did not exceed 10 cm in height.

The Martin Mid-East team also explains that the Gulfs sands tend to solidify into hard

substratum that later gets covered in layers of lose sand.

Submarine lithification of sediments in the area appears to be rapid. Consequently, a layer of calcarenite underlies wide areas of sand. This formation is locally known as caprock and consists of sand grains held together by early marine aragonitic cements. The caprock can be covered by variable thickness

- 46 -

layers of sand and frequent probing is necessary to positively confirm the presence of caprock. (3)

The figure below, taken from Jumeirahs EIA, shows some of the sand-covered caprock

that MME encountered while surveying the area.

Figure 23: Martin Mid-East Show This Caprock Ledge and Black Sea-Squirt, Phallusia nigra

Reproduced from The Palm Jumeirahs EIA

After examining the geophysical aspects of the construction site, MME discusses

the ecological characteristics of the area and the organisms and habitat that would be

destroyed in the process of constructing The Palm. Martin Mid-East evaluated the

ecological characteristics of the overall area by sampling 246 points within a 500 m by

500m sampling grid. Sample points were evaluatedat the intersection of Northing and

Easting lines at 500m spacing (7). The MME team did not examine the entire

construction area (which measures 25,000,000 m2); they only examined a sample area

measuring 250,000m2which equals 1% of the construction zone and .33% of the total

marine area to affected by the islands construction. But their sampling method appears

adequate; for it involved sampling sediment, counting fish, and photographing the

benthic ecology:

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At each second sampling point a sediment sample was taken, while at every other sampling point a photograph was taken. At each point, an additional sample was evaluated approximately 1m from the original sample. This additional sample was only photographed, when significantly different to the original sample at the intercept of the Northing and Easting lines. Thus a total of 492 samples and spot observations covered the area of investigation in a dense net. (7) As for the results of the investigation, the MME team found little biodiversity;

Over 95% of the sampling points fell on bare substratum. Martin Mid-East found some

sea grasses (Halophila ovalis and Halodule uninervis), but these formed only sparse

patches and did not form dense seagrass meadows. The only other flora they found were

algae, especially Acanthophora spicifera forming long tufts on oyster beds and other hard

substrata (23). They also found several different species of marine fauna. The most

biologically diverse areas encountered consisted of rocky ridges and artificial reefs.

Some of the rocky reefs formed drop-offs 20-50 centimeters high that harbored

populations of reef fishes. Other rocky reefs were composed of piles of rock rubble.

While the MME investigators did not know the origins of those rocky rubble piles, they

hypothesized that the piles used to be coral before the coral framework broke down from

anthropogenic thermal stress.

These [rock pile] areas were found in the distance to shore that coral growths normally occur in Dubai. If these were indeed former coral areas, they would have been killed over a decade ago by thermal outflow from the nearby industrial installations. Since the thermal outflows still remain, regeneration is impossible. (8)

Since, the Arabian Gulf is already an ecosystem of extreme stress due to high

temperatures, high salinity, sharp temperature fluctuations, and low nutrient content, any

additional thermal stress from industrial processes could have easily killed nearby coral.

If the area was indeed continuously thermally stressed, the coral would not be able to

reestablish themselves.

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The other type of diverse habitat MME found consisted of artificial reefs. One

such reef had been constructed using tires and rocks. The EIAs Figure 6 shows the reef

teaming with fish and marine life. The tire reef will be buried under one of The Palms

upper fronds, but MME notes that the breakwater could provide much more habitat than

this tire reef did.

Figure 24: An Artificial Reef of Old Tires Attracts Snappers and An Arabian Angelfish

Reproduced with Permission from Nakheel

The Palm Jumeirah would also negatively affect marine wildlife. All mobile biota

would flee the area, and the benthic organisms in or near the construction zone would be

buried or asphyxiated. What organisms lived here pre-Palm Jumeirah?

In its analysis of the local fish population and the potential for local fishing, MME

states that fish counts yielded low numbers of benthic and demersal fish. According to

the fish counts, 35 species of fish inhabited the study area. The tiny, benthic Prawn-Goby

Cryptocentrus lutheri exhibited the most dominance and abundance. Other species that

MME frequently encountered were Mojarras (Gerres oyena and related species) and

banded Terapons (Terapon puta) (20). Some members of these species would die during

Palm Jumeirahs construction, especially the benthic Gobies; but according to MME,

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The species affected are very common. The fish species frequenting sandy and muddy

areas are highly mobile and could move away from the construction site. MME also

asserts that the pelagic fish, such as Carangidae and Scombridae, would flee the area, and

would not experience significant impacts.

But would this fish displacement affect local fishermen? The MME team

observed some fishing in the area but concluded that it was not important for subsistence

because the fish populations exhibited too low density to sufficiently sustain the

fishermen. Therefore, MME concluded that The Palm Jumeirah would not negatively

impact any local fisheries. (Interestingly, one of the local NGOs complained that Nakheel

was not giving back to the community of locals and fishermen.)

Martin Mid-Easts researchers also found many different kinds of invertebrates.

The fauna consisted primarily of bivalve shells burrowing sea-urchins, and surface-

feeding snails (8). In addition, they observed sponges, sea cucumbers, snails, sea

urchins, starfish, sea pens, corals, and dense pearl oyster (Pinctada radiata) beds. Still,

they commented Total biomass is usually low. Sometimes the oyster beds also

contained coral and sponges, in cohabitation. Martin Mid-East pointed out that these

oyster beds would die if Nakheel built The Palm Jumeirah. The construction process

will without doubt kill large areas of oysters, this will, however, not endanger the

species. A complete list of all the observed taxa follows.

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Figure 25: List of Fauna (Besides Fish) Observed by Martin Mid-East at The Palm Jumeirah Reproduced with permission from Nakheel

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The construction process would kill not only oysters, but also coral; although

according to MME, coral were rare in the sampled area. Martin Mid-East states that

sparse colonies of Siderastrea siderea, Pseudosiderastrea tayamai, and faviids often

colonized Gulf caprock. The Martin Mid-East team expected some members of these

species to suffer mortality from The Palms construction. Although MME believed that

The Palm Jumeirahs construction would especially kill some coral, it also believed that

This will not have deleterious effects on local populations (9). In fact, MME expected

corals to recruit strongly to the newly-created, hard substratum on The Palm Jumeirahs

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breakwater, Therefore, the construction of Date Palm Island will likely enhance, rather

than disadvantage, local coral populations.

In sum, MME believed that impacts from Palm Jumeirahs construction would be

negligible and would not harm any critical or vital species.

In the area of immediate impact, i.e. the area that is to be filled, the result is obvious. The local fauna and flora will be completely and irrevocably lost. The area under question consists mainly of bare sand, one oysterbed and some areas of rocky ledge and artificial reef. While the sessile benthos and infauna will remain in the area and be killed, the mobile fauna elements will move away from the area of direct impact and most likely survive, Mobile fauna (fishes, other vertebrates, urchins) are not very site specific or territorial and will therefore not have problems resettling. The sessile benthos that will be killed does not consist of any rare or endangered species. Sufficient resources exist in the study area and in other areas of the Gulf. (24)

Of course, organisms can move away from a construction site only if the site is small

enough to allow them to exit it before they suffer too much damage. The smaller a

construction site is, the lesser its ecological harm. Hence, Nakheel needed to minimize

Palm Jumeirahs construction site.

To minimize the area affected and to prevent fine sediments from spreading to

areas surrounding the immediate construction site, MME suggested that Nakheel suspend

large silt screens (cloth screens that confine silt and minimize the chances for silt-plume

development) around the construction site. Martin Mid East was concerned that if silt

screens were not used, sediments would extend to areas surrounding The Palm. Those

suspended sediments could clog marine organisms gills and nutritive openings. Any

particularly fine sediments would remain suspended for long periods of time, afflicting

the resident biota. Eventually, the fine sediments would settle on the bottom but would

become re-suspended during storms, and thus, would resume afflicting the local marine

biotain an unending cycle. MME prepared a flow chart to demonstrate the

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environmental impacts it anticipates from The Palms construction including sediment

plumes. (See Figure 26, copied from the EIA.)

Figure 26: Palm Jumeirahs Impact Assessment Flowchart

Reproduced with permission from Nakheel

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Unfortunately, as Dr. Williams explains, Nakheel did not take MMEs advice

Nakheel did not use silt screens. Instead Nakheel allowed the plumes to extend many

kilometers beyond the construction site. Subsequently, says Dr. Williams, Palm

Jumeirahs construction affects an area three times its own size (according to estimates

by Nakheel). The Palm itself, being 5 km long and 5 km wide, directly impacts a 25-km2

area. Plumes of suspended sediments extend more than 25km2 to the left and 25 km2 to

the right of The Jumeirah Palm. Hence construction affects at least 75 km2 of the marine

environment.

An organism in the middle of the construction site would have to travel as far as 5

km out into the Gulf or as much as 35 km along the coast before it could escape direct

burial or asphyxiation by suspended sediments; therefore, I believe that most of the

marine organisms never escaped from that large area.

The findings of the United Nations University-International Network on Water,

Environment, and Health team support this theory. Nakheel had invited them to visit The

Palm projects and develop an ecological monitoring plan. In their 2004 report to Nakheel,

they state,

The construction of the islands has required massive dredging operations that have necessarily resulted in substantial resuspension of finer sediments, and the consequent siltation of benthic communities in the general region of each development. Continuous siltation over several months will have profound impacts on many benthic organisms, including smothering and death. (13)

However, the siltation lasted for much longer than several months because the

construction lasted longer than several months. Even in Mid-2004, three years after

construction began, siltation levels were still substantial at The Palm Jumeirah. At

present, waters outside the crescent contain a relatively high sediment load and visibility

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along the bottom third of the breakwall is very limited (1m) (16). This siltation

profoundly affected benthic organisms for several years.

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A CRITICAL ANALYSIS OF THE PALM JUMEIRAHS IMPACTS AND ITS EIA

It has been detrimental for the natural environment of the Dubai coast, especially at the place and location of the first Palm Island. There were very good habitats there. There were possibilities of recovery and protection, and there were possibilities of using that natural asset to make something.

Frederic Launay, Director of WWF-UAE Now let us analyze MMEs assessment. In this section I compare what MME has

reported in their Bathymetric, Geophysical, Marine Ecological, Topographic, and

Geotechnical Investigation to the information I gathered in the interviews.

You will recall that Martin Mid-East used findings from their survey of a 250,000

m2 area to estimate the ecological conditions in the entire 75km2 zone of impact. The area

observed for the EIA comprised only 1% of the 25km2 that The Palm will directly impact

and only .33% of the total zone of direct and indirect impact. Hence MMEs surveyors

would not have seen enough of the benthos to determine the pre-existing ecological

structure with statistical accuracy. Dr. Tom Williams argues that Martin Mid-Easts study

site does not accurately represent the predominant benthic environment. In the interview,

when I asked him Is the Martin Mid-East assessment reliable in your opinion? he

answered No. He went on to call the assessment inadequate.

Dr. Williams explained that the MME investigation served only as a preliminary

study. After reading the MME report, Nakheel decided to investigate further. In 2001, Dr.

Williams teamed up with Ali Sagar Al Suweidi, the Head of the Emirates Environmental

Marine Group, to ascertain the amount of coral cover in the area where The Palm

Jumeirah was to be built .(Of course, the tightlipped Ali Sagar Al Suweidi did not tell me

any of this when I interviewed him). They used over 3000 meters of transect and over 3

hours of handheld video during dives to study the benthic environment. The area they

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studied was not necessarily larger than the area MME studied. Yet, their results differed

markedly from those of MME.

Dr. Williams says that he and the Emirates Environmental Marine Group found

that coral patches alone covered an estimated 10%-15% of the substratum. Compare this

to MMEs finding of 5% of the substratum covered with anything living, including

corals, sponges, oysters, and other invertebrates. So whereas MME estimated that little or

no coral would die in the reclamation process, Ali Sagar and Dr. Williams estimate much

more coral death.

The following are Dr. Williamss calculations of the coral cover that The Palm

Jumeirah will destroy. The Palms immediate impact zone spans 25km2. But The Palm

will not cover every square meter within that zone. In fact, only one third (about 8.33

km2) of this direct impact zone would lie directly beneath The Palm, after its

construction. Based on Dr. Williams estimates that 10%-15% of this area hosts corals,

The Palm would bury approximately 0.83km2 to 1.25km2 of coral. This amounts to

between 832,500m2 and 1,